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    AFDO,

    May2

    1,2

    004

    Guidance for Processing

    sushi in Retail Operations

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    CreditsThe guidance for processing in retail operations has been prepared through support from the USDACooperative State Research, Education and Extension Service project no. 2001-11420 funded through theUniversity of Florida in cooperation with Florida A&M University and the Association of Food and Drug Officials

    (AFDO) during October 2001 through January 2004. Development of these respective guides was conductedby assigned voluntary Subcommittees combining academic, regulatory and industry expertise and a formalSteering Committee. The committee participants can be viewed in the Listing of Committee Members. Thesame information can be viewed at www.AFDO.org with additional visual aids and links to other websitesupport and references. Design by Julissa Hernandez. Printed by IFAS Communication Services.

    Project InvestigatorsVictor Garrido, University of FloridaRay Mobley, Florida A&M UniversitySteve Otwell, University of FloridaKeith Schneider, University of Florida

    Sushi SubcommitteeFaye Feldstein, Food & Drug AdministrationVictor Garrido, University of FloridaSteven Grover, National Restaurant AssociationJohn Lattimore, TX Department of AgricultureJeanette Lyon, Food & Drug AdministrationJanis McCabe, Publix SupermarketsSteve Otwell, University of Florida *Keith Schneider, University of FloridaJim Waddell, CA Department of Health

    *Lead coordinator

    Project Steering CommitteeJim Austin, AFDO Steve Otwell, University of FloridaShirley Bohm, FDA Paul Panico, OH Dept. of AgricultureAlfred Bugenhagen, NY Dept. Agric. & Markets Gale Prince, The Kroger Co.Joe Corby, NY Dept. Agric. & Markets Fred Reimers, HEB Grocery Co.Carl Custer, USDA FSIS OPH B Denise Rooney, AFDOFaye Felstein, FDA Doug Saunders, VA Dept. of AgricultureDan Sowards, TX Dept. of Health Keith Schneider, University of FloridaVictor Garrido, University of Florida Jenny Scott, Natl. Food Processors Assn.Steven Grover, National Restaurant Assoc. Timothy Weigner, Food Marketing Institute

    Janis McCabe, Publix Supermarkets, Inc. Gerald Wojtala, MI Dept. of AgricultureRay Mobley, Florida A&M University Betsy Woodward, AFDO

    Guidance for Processing Sushi in Retail Operations 2

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    BackgroundThis guidance has been prepared in response to a notable increase in on-site retail processing (manufactur-ing) of foods traditionally processed in controlled plant environments. Such retail processing can involve, butis not limited to acidifying, smoking, drying, fermenting, curing, reduced oxygen packaging, and other opera-

    tions that are traditionally done at a food manufacturing plant level. The key distinction for processing asrelated to this guidance is that the processing occurs on-site in the retail setting.

    This guidance is intended for retailers and regulatory personnel to help understand the controls to implementin a retail operation in order to process and sell safe food products. It can be referenced in developing consid-erations for variances for any exception or special provision to state or local food safety or sanitary codes. Itaddresses those special variances required by the FDA Food Code which may require HACCP plans for those

    jurisdictions that have adopted those portions of the FDA Food Code. In addition, it also applies to regulatoryoversight and/or approval for regulatory overlap that may occur between the states processing requirementsand the state or local retail food safety and sanitary codes. This guidance assumes retail compliance with appli-cable retail food codes, prerequisite standard sanitary operations procedures, and labeling requirements spec-ified in 21 CFR 101. This guidance is not intended to replace or duplicate existing regulations, but it does offera reference for more uniform practices.

    DisclaimerThis guidance is not a binding set of requirements. The information provided in the guidance are recommen-dations based on current science, commercial experience and practical considerations as assembled by theassigned committees and reviewed by a variety of selected experts and the Project Steering Committee. Useof these recommendations would likely result in retail processing practices that are acceptable to the pertinentauthorities for food safety. Retail compliance and enforcement will remain within the interpretations and deci-sions of the pertinent state and local regulatory authorities.

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    Product DescriptionThis recommended guidance is for sushi and related products (raw or cooked) either in the form of individualslices or combined in rolls made with acidified rice, seafood and vegetables, or similar rolls with vegetablesalone, prepared in the retail establishment by combining the necessary ingredients, and packaged for display

    in refrigerated cases for public sale.

    Related terminology:

    Approved source - a source that has been determined to conform to principles, practices, and standardsthat protect public health.

    Identifiable source - can include the name and address of the immediate supplier and the actual sourceor location of the supplies.

    Potentially hazardous food - means a food that is natural or synthetic and that requires temperaturecontrol because it is in a form capable of supporting the rapid and progressive growth of infectious ortoxigenic microorganisms or the growth and toxin production of Clostridium botulinum. Potentially haz-

    ardous food includes an animal food that is raw or heat-treated, shell eggs, or a food of plant originthat is heat-treated or consists of raw seed spouts, cut melons, and garlic-in-oil mixtures that are notmodified in a way that results in mixtures that do not support growth as specified in this definition.

    Sushi - ready-to-eat cooked rice that has been acidified with vinegar solutions formed with raw orcooked fish and other seafood such as imitation crabmeat made from surimi, fresh chopped vegeta-bles, pickles, tofu, etc. Product forms can include; Nigiri, small balls of rice with raw fish held in placewith strips of dried seaweed (nori); Maki Rolls, layers of rice and nori sheets rolled with a bamboo matto form cylinders that contain various seafood, vegetables and other ingredients, i.e., California roll(cucumber, avocado and surimi crab), Philly roll (with cream cheese), Tekka maki (raw tuna); and Handrolls, cone shaped rolls formed by a sheet of nori filled with various ingredients.

    Sashimi - thin slices or slabs of raw fish that are presented ready-to-eat.

    Surimi - a type of gelled fish paste that can be used to make simulated seafood products such as fab-ricated crab meat that can be used in sushi.

    Shamoji - Japanese term for the spatula or spoon used to turn and spread the sushi rice.

    Wasabi - Japanese hot mustard-type paste used to accompany sushi and sashimi.

    Guidance for Processing Sushi in Retail Operations 4

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    Flow Diagram of Operations

    Receiving

    Food Storage

    Preparation

    Display

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    Guidance for Processing Sushi in Retail Operations 6

    Check List for Operations

    Receiving

    All food is obtained from an identifiable, approved source. The source or supplier should be operating inaccordance with applicable food safety requirements. Source identity can include the name andaddress of the immediate supplier that will be the first link to the actual source or location of the sup-plies. Identity of the supplier provides traceability of the food sources which can be important in foodsafety decisions. For seafood, this can include identity for approved harvest waters, prior handling con-ditions, and duration and methods of transport. No seafood from a recreational fisherman or other non-approved sources is used in the sushi operations.

    All seafood, including fish, shellfish, crustaceans, eggs (roe) and surimi comes from a source that operatesunder a HACCP plan. Evidence for such a source can include a letter from the supplier that indicatescompliance with any pertinent HACCP requirements. In some instances, this HACCP information canbe obtained upon request. The HACCP information and prior supplier agreements with the sushi oper-ation should provide controls to prevent potential food safety hazards due to parasites in certain rawfish, elevated histamine levels in certain fish, and other seafood safety concerns (Appendix 1 - FoodSafety Hazards).

    Certain fish will require freezing either by the suppliers or retail operations prior to serving as a raw ready-

    to-eat item due to potential parasite problems (see controls for parasites in Appendix 1 - Food SafetyHazards).

    Vegetables, both whole and pre-cuts, and other edible products, i.e., seaweed (nori), vinegar, and spices,are obtained from approved and identifiable sources.

    If commercially prepared, pre-acidified sushi rice isused, it should be obtained from an approved and iden-tifiable source operating under a HACCP plan which includes records for the rice production within limitsoutlined in thisguide. If pre-acidified rice or flavored vinegar is provided from a source outside the sushioperations, this source should be approved, identifiable and able to provide processing records thatdocument proper acidification, and the duration and temperature for storage similar to the recom-mended guidelines for sushi operations (Appendix 2 - Sushi Rice).

    All potentially hazardous foods are delivered at or below 41F (5C) or solidly frozen. A calibrated ther-mometer is used to monitor the internal and/or surface temperature of the incoming foods beforeacceptance (Appendix 3 - Calibrations).

    Retail establishment actively manages a program for routine inspection of incoming products for approvedsources, product condition and temperature as necessary, integrity of packaging and proper label informa-tion, and documents product acceptance or rejection with dates, times and the person making the deci-sion, plus any necessary comments.

    Food Storage

    All foods should be protected from contamination and stored in a manner to reduce or prevent bacterialgrowth that could promote spoilage or potential food safety problems. Food storage can involve items held atroom temperature or in refrigeration or freezers. These items may require further preparation or packaging,or they could be ready-to-eat as raw or previously cooked foods. Raw ingredients and raw, unprepared foodsshould be stored segregated from finished products or ready-to-eat foods. It is best to segregate these itemsin separate storage units. Proper packaging and placement is necessary when these items have to be storedin the same unit. Storage can include temperature control units used to hold perishable foods.

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    The storage unit(s) are clean and orderly.

    Products are contained and/or covered for protection.

    Containers of sushi products or ingredients that are removed from the original (identified)

    packages are relabeled, marked for identification and dated.Ready-to-eat items and items ready-for-display are segregated from products that requirefurther handling or processing.

    Products are not stacked without adequate support and means to prevent any leakagebetween products.

    Drippage is prevented in or on packaged products due to condensation, cooler pan leaks orother wet sources.

    Products are stored above the floor (approx. 6 inches) and away from walls and the ceiling.Storage includes containers, shelves, supports, pallets or other materials that do not absorbwater and can be easily cleaned.

    The schedule for product rotation should use a First-in First-out rule (FIFO).

    Display counters are not considered storage units and should not be used to store raw ingredients. Displaycounters for sushi should be maintained at or below 41F (5C).

    Refrigeration unit(s) are operating to assure the food can be maintained at or below 41F (5C).

    Frozen storage unit(s) are operating to assure the frozen foods are solidly frozen and maintainedpreferably at or below 0oF (-18C). Freezing to kill potential parasites requires frozen storage at -4F(-20C) or below for 7 days (total time), or freezing at -31F (-35C) or below until solid and stored at-31F or below for 15 hours, or freezing at -31oF or below until solid and stored at -4F or below for 24hours.

    Routine monitoring for proper refrigerated storage unit temperatures involves use of a continuoustime-temperature recording device or by periodic checks with a calibrated thermometer. All recorders andthermometers are calibrated periodically or as needed (Appendix 3 - Calibrations). When storageconditions above 41F (5C) are detected, an evaluation is conducted of all products stored in the unit.The evaluations will record considerations for the actual temperature of the products and duration ofexposure. All unacceptable temperature abused, off-color, off-odor, off-condition, out-of-date or other-wise suspect product is discarded.

    Frozen products are thawed under refrigeration at or below 41F (5C). Thaw in a manner that preventscross-contamination with other refrigerated foods. If more rapid thawing is necessary, the products areplaced in clean flowing water no warmer than 70F (21C) only until thawing is complete. Onceproduct is thawed and before exceeding 41F (5C), it should be processed or returned to proper refrig-erated storage. Packaging is recommended to protect the product from direct contact with the thaw

    water. If thawing requires direct contact of water with the food, the procedure should be conducted ina clean and sanitized sink or container that is designated and dedicated to this operation. Thawing isnot conducted in standing water, at room temperature or in running water warmer than 70F (21C) orat room temperature.

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    Guidance for Processing Sushi in Retail Operations 8

    Preparation Sushi

    The work area, facilities and utensils should be designated or dedicated to the sushi operations. If it isnecessary to share work space and facilities, a schedule of operations, personnel traffic, product traf-

    fic and cleaning should be planned to prevent potential cross-contamination of the ready-to-eat sushiproducts.

    Standard Operating Procedures for basic sanitation and food safety are used and documented daily(Appendix 5 - Daily SOPs Check List).

    Bamboo and plastic mats are lined with plastic film and rewrapped within 4 hours of continuous use andbetween contact with different sushi products. All mats are cleaned and sanitized daily.

    The preparation schedule should be arranged to prevent the exposure of potentially hazardous foods formore than 4 hours outside of refrigeration.

    Fruits and vegetables should be washed before cutting for use in sushi. Any cutting surface should becleaned to avoid cross-contamination before proceeding with further processing for the sushi.

    On-Site Preparation of Sushi Rice

    Special care is taken in preparation of the rice used with sushi to prevent potential bacterial growth while assur-ing the rice can still be formed into balls and rolls. Bare hand contact should be minimized to prevent cross-contamination of the ready-to-eat product. Heat during the cooking of rice can activate certain bacterial sporesthat can grow and release toxins unless the rice is preserved or refrigerated. Refrigerated rice is more difficultto form for sushi. For this reason, sushi rice should be carefully protected during handling without refrigeration.Proper acidification of cooked rice with vinegar recipes helps preserve the rice for temporary handling at tem-peratures above 41F (5C), but the acid level, measured by pH, should be carefully monitored for each batch.

    It is best to acidify the rice when it is warm to assure better mixing and penetration of the acid solution.The production time and final acid level (pH) is recorded for each batch of sushi rice. Acidified rice has aninitial measurable, targeted pH of 4.1 and should be thoroughly mixed to assure the rice does notexceed an equilibrium pH of 4.6 (Appendix 2 - Sushi Rice). Properly acidified rice is not considered apotentially hazardous food.

    Display

    Display involves holding the finished products in temperature control units for a specified duration and condi-tion for public sale. Originally, preparation of sushi was for immediate consumption. Retail preparation and dis-

    play introduces more prolonged holding that should be controlled and monitored to assure product safetybefore consumption.

    The display unit maintains the sushi products at or below 41F (5C).

    Packaged product should be properly labeled and include instructions for proper storage and shelf-life(Appendix 4 - Product Labels). Typically the product is displayed for less than 24 hours in the retailestablishment before discarding. Displayed product is not placed in storage for later display. Lot and/ordate coding is recommended.

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    Appendices

    1. Food Safety Hazards

    2. Sushi Rice

    3. Calibrations

    4. Product Labels5. Daily SOP Check List

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    Guidance for Processing Sushi in Retail Operations 10

    Appendix 1 Food Safety Hazards Sushi

    The following information and list of fish species with potential seafood safety hazards is based on FDAs Fish& Fisheries Products Hazards & Controls Guidance available in third edition (June 2001) from or by phone 800-226-1764 as publication no. SGR-121 ($20) or it can be viewed atwww.cfsan.fda.gov/~comm/haccp4.html. The retail processing of sushi must assure the use of proper controlsto prevent, eliminate or reduce these potential hazards. The controls are often a shared responsibility betweenthe supplier and retailer.

    Fish:The list of potential fish hazards includes live parasites, elevated histamine, the natural toxin, ciguatera, andno hazard listed. The listing is by common names of certain related fish species. Retailers should consult theFDA Hazards Guide for the specific fish species in question. Species listed with concerns for live parasiteswould require freezing either by the supplier or retailer prior to serving a raw ready-to-eat food.* For tuna, theconcern for parasites is distinguished by species. The larger tuna (yellowfin, bluefin, blackfin, bigeye, and alba-core) do not present a significant parasite problem that would require freezing prior to use in sushi.

    parasites histamine ciguatera no hazard

    Bass, Sea

    Bluefish

    Cod

    Corvina

    Eel

    Flounders

    Grouper

    Halibut

    Jacks

    Mackerels

    Mahi-Mahi

    Marlin

    Perch, Ocean

    Pollock

    Pompano

    Salmon

    Sea Trout

    Snappers

    Sole

    Rainb. Trout

    Tuna - small*

    Tuna - large*

    Turbot

    Wahoo

    Yellowtail

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    Crustaceans (Shellfish):

    Crab, Lobster and Shrimp - typically supplied as previously cooked items that are subject to bacterial cross-con-tamination after cooking. These items can include surimi based products such as imitation crab meat madefrom fish. Retailers should question the processing procedures, post-processing conditions, and sanitation

    records prior to selecting a supplier.

    Mollusk (Shellfish):

    Clams, Oyster and Mussels - must be harvested from approved waters and handled by certified dealers thatmaintain harvest tags on shellstock or labels on the shucked products to identify the product harvest locationsand dates. Retailers must check for the tags or label information on all deliveries of shellstock or shuckedmeats (meat removed from the shell). The shellstock tags must be stored in their retail establishment for 90days. Abalone is included in this group but does not require tags.

    Conch, Whelks, Octopus, Squid and Urchin - typically supplied as raw shucked meat (meat removed from theshell) that is subject to bacterial contamination during processing. Harvest tags are not required but suppliersshould assure harvest from safe sites. Retailers should determine the processing and sanitation conditions.

    Biological

    Hazard: Parasites

    Problem: Consumption of certain raw seafood that may contain live parasites that are naturally found incertain fish and could infect consumers.

    Controls: Freezing or cooking of the fish or seafood product before consumption. According to the FDAs FoodCode, seafood is properly cooked when it reaches an internal temperature of 145F (63C) for 15 seconds.Freezing to kill potential parasites requires frozen storage at -4F (-20C) or below for 7 days (total time), or

    freezing at -31F (-35C) or below until solid and stored at -31F or below for 15 hours, or freezing at -31F orbelow until solid and stored at -4F (-20C) or below for 24 hours.

    Hazards: Bacterial and Viral Pathogens

    Problem: Certain bacteria, i.e., Salmonella, Listeria and Vibriospp. and certain viruses, i.e., Hepatitis A,noroviruses and others, can contaminate and, in the case of bacteria, grow on ready-to-eat sushi productsdue to previous handling of the ingredients.

    Controls: Ensure that ingredients come from approved sources, monitor condition of incoming products, main-tain and monitor proper temperatures and time in storage and preparation; properly acidify the sushi rice,practice proper hygiene, and monitor SOPs for sanitation.

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    Guidance for Processing Sushi in Retail Operations 12

    Chemical

    Hazard: Histamines

    Problem: Certain fish are prone to develop an elevated histamine content, the result of bacterial degradation ofhistidine, if they are thermally abused after harvest and during further handling. They can cause temporary ill-nesses in some people following consumption of the raw or cooked fish.

    Controls: Proper handling time and temperatures that provide immediate and proper refrigeration or freezing ofthe fish as evident in a suppliers HACCP program, and continuing refrigeration or frozen storage until con-sumed. Retailers should examine each fish or fish portions carefully for signs of thermal abuse or initial decom-position. Questionable fish and fish with a temperature in excess of 41oF should be rejected.

    Hazard: Ciguatera

    Problem: A natural toxin that can accumulate through the normal food chain of certain fish that can cause ill-ness in some consumers when the fish is eaten raw or cooked.

    Controls: Do not use certain fish species when harvested from known or designated areas that are problemat-ic for ciguatera. The original producer or suppliers HACCP program should monitor to prevent harvest and useof such fish. Potential problems can not be detected by sensory judgments of the raw or cooked fish.

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    Appendix 2 Sushi Rice

    Special care is taken in preparation of the rice used in sushi to prevent potential bacterial growth while assur-ing the rice can still be formed into balls and rolls. Heat during the cooking of rice can activate certain bacter-ial spores that can grow to be toxic unless the rice is preserved or refrigerated. Refrigerated rice is more diffi-cult to form for sushi. Acidification of cooked rice with vinegar recipes helps preserve the rice for temporaryhandling at temperatures above 41F (5C), but the acid level, measured by pH, must be carefully monitoredfor each batch.

    Preparation of the Sushi Rice (white)

    The work area should include:

    A dedicated or designated sink and table for preparation of the rice and sushi should be cleaned andsanitized before handling the food. A designated sink should be segregated from other concurrent foodhandling activities.

    Use of single-use gloves to prevent bare hand contact with ready-to-eat food.

    Clean and properly supplied hand washing facilities.

    Orderly storage of clean, sanitized containers and utensils, i.e., rice bowls and shamoji for handling therice.

    A written recipe that specifies:

    the amount of rice and water prior to cooking, and the cook schedule. The cooked rice andvinegar solution is to be thoroughly mixed to acidify the rice to an initial target pH of 4.1. It isbest to acidify the rice when it is warm to assure better mixing and penetration of the acid solu-tion.

    the vinegar solution, with salts and sugar. It should be made fresh for use or from a designat-ed container labeled to identify the contents, concentration and age of the vinegar solution toassure a proper acidifying formulation.

    a clean mixing bowl deep enough to allow adequate mixing without clumping, yet shallowenough to allow proper cooling. It is best to have less than 4 inches depth in the rice forproper cooling.

    Special Note: The initial pH of the sushi rice should be measured within 30 minutes after addition of the vinegar solution. The sushi ricewith an initial pH greater than 4.6 should be re-acidified with more vinegar solution and rechecked to assure a targeted pH of 4.1 and anequilibrium pH that does not exceed 4.6. Sushi rice must be mixed, measured for pH, and comply with the limits prior to being used in asushi robot device.

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    Guidance for Processing Sushi in Retail Operations 14

    Measuring & Recording pH of the Sushi Rice

    Conduct the pH test within 30 minutes after acidification of the cooked rice and as often as necessaryto assure a targeted pH of 4.1 and an equilibrium pH of 4.6.

    Make a rice slurry by gathering a 1/4 cup sample of the cooked, acidified rice taken from various loca-tions in the batch and add 3/4 cup of distilled water in a clear plastic or metal blend cup (Do not useglass containers in the food preparation area). Blend the slurry for approximately 20 seconds to createa thorough mix.

    Insert a pH probe or paper into the liquid portion of the slurry. Repeated measurements with a newslurry from the same batch of rice are recommended to assure a proper reading (Appendix 3 -Calibrations)

    Record the measurement(s).

    Brown Rice

    Typically this rice is not acidified since the harder surface coating on the brown rice is difficult to penetrate withtypical acid solutions. In the non-acidified condition, cooked rice is considered a potentially hazardous food that

    must be maintained at a temperature greater than 135F (57.2C) or at or below 41F (5C). For cooling, thispotentially hazardous food should be cooled within 2 hours from 135F (57.2C) to 70oF (21C); and within 4hours from 70F (21C) to 41F (5C) or below. The cooked brown rice should be chilled immediately afterpreparation to reduce the chance of foodborne illness.

    1/4 cup of acidified rice 1/2 cup of destilled water

    mix into a slurry

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    Appendix 3 Calibrations

    Temperature Monitoring Devices-Thermometers

    Many types of thermometers and temperature recording devices are readily available for use in food handlingoperations. We recommend thermistors, thermocouples and infrared thermometers with either a digital or ana-log readout. All of these instruments are acceptable for use in the food processing operations as long as theoperator understands how they are used and if they are calibrated for proper readings.

    The method and frequency of calibration for thermometers will depend on the use and temperature rangewhere the equipment is used. In the absence of manufactures recommendations, thermometers should be cal-ibrated at least once a month with more frequent calibrations when the instrument is physically abused or if thereadings are questionable.

    Temperature Monitoring Devices (TMD) - Calibration Procedures (options):

    a. TMDs can be calibrated against a thermometer certified by theNational Institute of Standards and Technology (NIST) by simplycomparing both units at two preset temperatures (hot and cold).

    b. TMDs can be calibrated using an ice-water slush. Insert the temper-ature probe into a mixture of ice and water slush and stir (2-3 min)

    until the thermometer stabilizes. The probe should be at the centerof the container. The thermometer should read 321F (01C).Adjust accordingly or discard and replace the faulty thermometer.

    c. Hot point calibration is used when monitoring temperatures higherthan room temperature (e.g., cooking temperatures). Heating blocksor boiling water can be used for this calibration. When using the boil-ing water procedure, the probe is placed inside a container with boil-ing water until the thermometer stabilizes (2-3 min). The probeshould be at the center of the container. The thermometer shouldread 2121F (1001C) or appropriate temperature according toelevation (Table 1 - Altitude to Boiling Point of Pure WaterRelationship). Adjust accordingly or discard and replace the faulty

    thermometer.

    d. A combination of the procedures b and c is recommended for a moreaccurate calibration of thermometers used to monitor a wide rangeof temperatures.

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    Guidance for Processing Sushi in Retail Operations 16

    Altitude to Boiling Point of Pure Water RelationshipFeet Above Sea Level Boiling Point (F)

    0 212

    500 2111,000 210

    1,500 209

    2,000 208

    2,500 207

    3,000 206

    3,500 205

    4,000 204

    4,500 203

    5,000 203

    6,000 201

    7,000 1998,000 197

    10,000 194

    12,000 190

    14,000 187

    Source: Thermometer Calibration, food safety webpage, University of Nebraska Cooperative Extension(http://foodsafety.unl.edu/html/thermometer.html)

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    Acidity Monitoring Devices - pH Meters & pH Papers

    Devices for monitoring acidity or pH can range from complex laboratory size units to convenient hand-held bat-tery operated units. Also, in certain situations firms can use simple pH test strips or papers. It is essential to

    understand the limitations and operation of these devices to assure accurate readings in food operations. Themeters are preferred for their more precise readings, but the probes used with the meters should be made ofunbreakable substances such as epoxys, plastics or ceramics. The pH papers are less precise and subject tointerference with other substances. Selection of papers should consider reading increments of 0.2 within a pHrange about the target levels to be monitored in the food operation (i.e., If the target level is 4.1, the papershould be selected for a range of 3.0 to 5.0).

    Calibration of pH Monitoring Devices

    The pH meters need to be calibrated immediately before use and when readings are suspect. The calibrationis based on the readings from standard buffer solutions selected to provide specific pH readings. Only usebuffers that have not exceeded the labeled expiration dates. Use buffers that provide readings that range aboutthe targeted level of pH to be monitored in the food operations. For example, if the target pH is 4.1, two buffers

    for calibration should provide readings of 4.0 and 7.0. If the pH meter does not read the buffers correctly, makethe necessary adjustment in the device according to the manufacturers instructions or replace the device.

    The pH papers or strips are usually not calibrated, but firms are encouraged to test their papers against resultsfrom a calibrated pH meter and buffers. Make sure that the strips used are adequate for the pH range neededand that the shelf-life of the strips does not exceed the labeled expiration date.

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    Guidance for Processing Sushi in Retail Operations 18

    Appendix 4 Product Labels

    All sushi product sold through display in a retail setting must be in compliance with applicable state food coderequirements and contain information pursuant to the requirement of 21 CFR 101. In addition, information onthe product label that informs the consumer on proper handling to prevent potential food safety problems isrecommended (i.e., PERISHABLE KEEP REFRIGERATED AT 41oF OR BELOW - BEST IF CONSUMED ONDAY OF PURCHASE). The label must identify specific seafood present and whether or not it is raw.

    Label Information1. Identify specific seafood present.

    2. Indicate that the product does or does not contain raw seafood.

    3. Include perishable food statement to instruct consumer handling and storage (i.e., PERISHABLEKEEP REFRIGERATED. BEST IF CONSUMED ON DAY OF PURCHASE).

    4. Lot and/or date code the product.

    5. Name, address of food establishment.

    Disclaimer: This label is simply provided as a guide. Retailers should consult with theirlocal authorities to assure compliance with more immediate requirements in their region.

    Labeling - Consumer Advisories

    Certain states may require use of consumer advisories either as part of the label, information and/or in signsposted about the sushi display. The cautionary message is intended for persons with weakened immune sys-tems that are at more risk from potentially hazardous foods such as raw seafood used in certain sushi. Stateauthorities should be consulted for compliance. Typical wording in advisories state, Consuming raw or under-cooked foods of animal origin may increase your risk of foodborne illness, especially if you have a certain med-

    ical condition or reduced immunity.

    SUSHI Roll

    Raw Seafood No Raw Seafood

    Ingredients: Cooked rice, seafood (see list), cucumber,vinegar, sugar, seaweed, salt

    Tuna Raw Salmon Smoked Salmon

    Shrimp Yellowtail Snapper

    Other

    PERISHABLE: Keep Refrigerated at or below 41FBest to Consume On Day of Purchase

    Net Weight 8oz

    10/15/03

    Any Sushi Company, Inc., P.O. Box 1111, Anywhere, State, USA 11111

    1

    2

    3

    4

    5

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    Appendix 5 Daily SOP Check list

    Store Name/Number: ________________________________________ DATE: _________________

    Storage Time/Temp Time/Temp Time/Temp Time/Temp

    Refrigerators (F / Time) F F F F

    Freezers (F / Time) F F F F

    Display Time/Temp Time/Temp Time/Temp Time/Temp

    Display temperature (F / Time) F F F F

    Clean and Orderly. Food in good conditionand properly labeled.

    Sushi Rice Preparation Prep Time

    Rice pH

    Lot #

    SOP CHECK LIST

    Work Area Comments

    Orderly; Clean and Sanitized tables,countertops and sinks. Orderly, all work

    surfaces cleared. Clean floor and drains

    Proper storage and labeling of chemicalsand cleaning items

    Wet and dry trash separate and removedfrom work area.

    All utensils, pots, pans, bowls, cutting boards,cooking or heating equipment properly cleanedand sanitized.

    Thermometer and recorder availableand calibrated

    Personnel

    Personnel Health, hand-washing practices,glove use, clean and well maintained outergarments, proper hair covering and no jewelry.

    Food Storage

    All food protected, dated and labeled properly

    Refrigerators and freezers clean, orderly andoperating correctly.

    Pre-Op Time Post-Op Time

    Employee Initials

    Manager Review

    This particular form is not mandated but it does indicate information that should be recorded to demonstrate an appropriate process forfood safety. Different and additional forms can be used to record the same information.

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